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Stationary Source
Greenhouse Gas Emissions Threshold for CEQA
Board of Directors
Santa Barbara County
Air Pollution Control District
Molly Pearson
Planning & Grants Supervisor
April 16, 2015
• Project description and application
• Summary of the public process
• Threshold options
• Community Advisory Council and Next Steps
• Questions
Overview
Project Description
• Establish a stationary source
greenhouse gas (GHG) threshold of
significance to be used by the District
when acting as a lead agency under the
California Environmental Quality Act
(CEQA)
• Incorporate threshold into the
District’s Environmental Review Guidelines
Application
• Threshold would apply to new or modified stationary
sources (e.g. oil and gas facilities, landfills, hospitals or
universities, and a wide range of other types of facilities
that have combustion devices)
• Threshold used when the District is the CEQA lead agency
• Other lead agencies are encouraged to use the District’s
threshold
GHG Inventory
Threshold would
apply to this sector
Total CO2 Emissions in
2007 Inventory = 5.18
million metric tons CO2
Public Involvement
• Thorough outreach and noticing
• Four public workshops: two in May 2014, one in December
2014, one in March 2015
• Stakeholder meetings open to the public
• Regular email updates on project activities
• Solicitation of verbal and written input
• Posting on our website of all written input and notes from
workshops
Public Workshops
• May 6 and 8, 2014 – Santa Maria and Santa Barbara
– Background
– Early input – verbal and written
• December 3, 2014 – Santa Barbara
– Presented input received from the public
– Four potential options for consideration and discussion
• March 25, 2015 – Buellton
– Presented two potential options
Staff Report
• Developed prior to March 25, 2015 joint public
workshop/CAC meeting
• Widely noticed and posted online in advance
• Includes:
– Background, public process, local/state/federal initiatives
– Responses to comments and requests from the public
– Two options for consideration, with substantial evidence to
support both options
Responses to Comments and Asks
Asked for capture rate for 10,000 MT threshold, and
what threshold would be at 95% capture
Developed Table 5-1 that explores bright line
threshold levels based on various capture rates,
including 95% capture
Asked for more information regarding the stationary
source GHG inventory, source types
Developed Figure 5-1 and 5-2 that show # of sources
in various emissions brackets
Asked for definition of BAU Provided a definition and explanation of expectations
of a BAU analysis in Section 6
Asked to show mitigation calculation for a 87,000
MT/yr project under performance-based measure
threshold
Performance-based measure threshold option not
moved forward so request no longer applicable
Asked for justification for using 2020 versus 2050
targets for the percent reduction required
Section 6 includes an explanation of why the 2020
reduction value is referenced at this point;
commitment to revisit when post-2020 targets are
adopted
Responses to Comments and Asks
Asked for more details on mitigation & monitoring Preparing a mitigation “white paper”
Asked to clarify position on acceptability of
purchased, Cap-and-Trade compliance offsets
Discussion included in Section 6; yes, purchased
offsets from projects done under a CARB-approval
protocol are acceptable mitigation
Asked to clarify position on purchased vs. allocated
allowances
Discussion included in Section 6; compliance
obligations above and beyond what is freely allocated
represent a GHG reduction
Table 5-1: Hypothetical Bright-Line Significance Thresholds
Threshold Level
(MT CO2e)
Percentage of
Emissions
Captured
Number of Sources Within Santa
Barbara County Total County-Wide
Emissions Within
Category
Above
Threshold
Below
Threshold
Zero 100.0% 418 0 1,001,607
1,000 98.6% 71 347 987,481
5,000 89.1% 23 395 891,978
10,000 82.4% 12 406 818,506
25,000 74.1% 7 411 730,578
Percent Capture
Rate
Emissions Level
(MT CO2e)
Number of Sources Within Santa
Barbara County Total County-Wide
Emissions Within
Category
Above
Threshold
Below
Threshold
80% Capture 16,315 8 410 750,985
85% Capture 7,422 17 401 858,126
90% Capture 3,974 25 393 900,130
95% Capture 1,754 44 374 950,701
98% Capture 1,149 65 353 981,139
100% Capture Zero 418 0 1,001,607
Note: All values are approximate
Zero Threshold
• Many commenters urged adoption of a zero threshold
• Consistent with the science of climate change
• Challenging to implement:
– Even small sources subject to potentially costly environmental review
– Administrative and financial burden on agencies and project proponents:
mitigation funding, environmental review, mitigation monitoring & reporting
• Only achieves a small amount of additional reductions, but
subjects many more small sources to substantial administrative
requirements
Threshold Options
Bright Line 10,000 MT/yr
AB 32 Consistency
Bright Line 10,000 MT/yr Threshold
• Establishes a strictly numeric emissions threshold and requires
mitigation to below 10,000 MT to make a finding of less than
significant
• Capture rate of 82.4% on 2013 County GHG stationary source
emissions
• Threshold set low enough to capture a substantial fraction of
future emissions, while high enough to exclude small projects
• Applied in California and to date has not been challenged in the
courts
AB 32 Consistency Threshold
• Utilizes a 10,000 MT/yr screening threshold and considers Cap-and-Trade as
a Qualified Greenhouse Gas Reduction Plan
• Requires a 15.3% reduction from business-as-usual (BAU) emissions
• The “% reduction from BAU” method has been challenged (successfully and
unsuccessfully) in the courts
• Commitment to update % reduction as the state adopts new reduction targets
Comparison of Mitigation Examples
Project subject to a Bright Line 10,000 MT/yr
Threshold
Project subject to the Cap and Trade Program
(under AB 32 Consistency Threshold Approach)
Comparison of Mitigation Requirements (30 yr project life)
Mitigation
Basic requirements:
• Relates directly to the impact, roughly proportional to the impact
• “Fair share” funding of a measure that addresses the cumulative
impact
• Should not be deferred
• Done up-front or through a mitigation monitoring & reporting plan
• Offsets = real, quantifiable, surplus, enforceable, and permanent
Mitigation
Priority:
• onsite reductions first
• offsite within the region
• elsewhere in California
• elsewhere in the U.S.
Preparing a “Mitigation White Paper” with additional information on
how to implement mitigation for different scenarios.
Community Advisory Council Consideration
• Presented to CAC on March 25, 2015, concurrent with public
workshop presentation
• Received public comment at joint workshop/CAC meeting
• Discussion and deliberation amongst CAC members
• Majority of the CAC voted to recommend the AB 32 Consistency
threshold to your Board (15 out of 22)
• Minority also forwarded a letter to your Board
Next Steps
• Board to consider threshold options and CAC
recommendations on May 21, 2015:
– Adopt a GHG threshold for projects when APCD is CEQA lead
agency
– Review and consider approval of other changes to
Environmental Review Guidelines
Questions?
Thank you